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ABThe International MarineContractors Association

Norway/UK Regulatory

Guidance for Offshore Diving

(NURGOD)

www.imca-int.comIMCA D 034December 2003

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Norway/UK Regulatory Guidance for Offshore Diving

IMCA D 034 December 2003

1 Introduction and Scope.................................................................................................... 11.1 General ......................................................................................................................................................................................11.2 Background ...............................................................................................................................................................................11.3 Objectives .................................................................................................................................................................................11.4 Assumptions .............................................................................................................................................................................11.5 Methodology.............................................................................................................................................................................2 1.6 Status of the Guidance ...........................................................................................................................................................21.7 Updating Arrangements .........................................................................................................................................................2

2 Normative References ..................................................................................................... 33 Administrative Requirements ......................................................................................... 4

3.1 Organisation .............................................................................................................................................................................43.2 Administrative Requirements ...............................................................................................................................................43.3 Management of Exceptions....................................................................................................................................................43.4 Application for Consent to Dive .........................................................................................................................................43.5 Documentation........................................................................................................................................................................53.6 Reporting...................................................................................................................................................................................7 3.7 Diving Contractors Contingency Centre..........................................................................................................................8

4 Health, Working Environment and Safety..................................................................... 94.1 Health Organisation................................................................................................................................................................94.2 Medical Equipment ..................................................................................................................................................................94.3 Suitable Doctors......................................................................................................................................................................94.4 Medical Checks ........................................................................................................................................................................94.5 Liaison with a Suitable Doctor ...........................................................................................................................................104.6 Nurse........................................................................................................................................................................................104.7 Safety Delegates.....................................................................................................................................................................104.8 Working Environment Committee ...................................................................................................................................10

5 Personnel Qualification Requirements......................................................................... 125.1 Familiarisation Process .........................................................................................................................................................125.2 Training and Competence ...................................................................................................................................................12

6 Technical Requirements ................................................................................................ 156.1 Diving Equipment - General................................................................................................................................................156.2 Maintenance and Certification Systems............................................................................................................................196.3 Support Vessel .......................................................................................................................................................................20

7 Operational Requirements............................................................................................ 227.1 Numbers of Personnel/Team Size .....................................................................................................................................227.2 Working Periods/Time Provisions.....................................................................................................................................227.3 General ....................................................................................................................................................................................24

8 Emergency and Contingency Equipment..................................................................... 278.1 Hyperbaric Evacuation..........................................................................................................................................................278.2 Habitats....................................................................................................................................................................................298.3 Plant & Equipment .................................................................................................................................................................29

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1 Introduction and Scope1.1 General

The offshore commercial diving industry, while providing services to the oil and gas industry, can bethe subject of various regulations and standards imposed by national governments of a particular area,

the clients who wish the work carried out, the insurers of the diving contractor or other outsidebodies.

The document is intended to assist the following, among others:

Personnel involved in diving operations;

Client's staff involved in the preparation of bid documents and contracts;

Client and diving contractor representatives;

Vessel owners and marine crews involved with diving operations;

All personnel involved in operational management.

In order to provide a common approach for diving contractors, this guidance seeks to lay downminimum requirements which all IMCA members should follow when transferring diving supportvessel (DSVs) between the UK and Norwegian regions and vice versa.

1.2 BackgroundUnited Kingdom and Norway each have their own set of legislation and guidance to which therespective diving contractors in the offshore oil industry have to abide. This bridging document hasbeen developed to provide standardisation of procedures and approaches for managing the regulatorydifferences between the two nations. This should ease the operational process for offshore divingacross the North Sea.

When crews and equipment from either UK or Norway are to operate in each others waters, it is

necessary that the operation is carried out in accordance with the national laws of the respectiveoffshore sector. That is, if a vessel crosses from UK to Norwegian waters it needs to satisfyNorwegian regulations in order to operate in the Norwegian sector. Likewise, if Norwegian crews orequipment cross from Norwegian to UK waters it is necessary that they operate according to UKregulations while in the UK sector.

1.3 ObjectivesThe main objective of this guidance document is to facilitate the use of diving vessels and resourcesbetween the two jurisdictions (UK and Norway); and add safety and efficiency to offshore divingoperations by developing a common approach via the use of this document. The document is basedon the assumption that the body of laws in the two countries is compatible in this context.

However, where differences have been identified the guidance highlights those differences.The process for revision of legislation is outwith the scope of this guidance.

1.4 AssumptionsIt is presupposed that UK operators and diving contractors satisfy the UK laws and regulations foroffshore diving operations. In the same manner, it is presumed that Norwegian operators and divingcontractors satisfy the Norwegian body of laws.

The preparation of this guidance has been conducted jointly by the industries in UK and Norwaywhereby OLF (Oljeindustriens Landsforening - The Norwegian Oil Industry Association) and IMCA

(International Marine Contractors Association) represent their respective members from theseindustries.

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Where the guidance does not refer to a specific sector it should be read as being good practice forboth sectors.

1.5 MethodologyThis document has been developed by IMCA members and reviewed by interested parties includingOLF, the Norwegian Petroleum Directorate (NPD) and the UK Health & Safety Executive (HSE).

The basis for the content of the document is a gap analysis which has been undertaken to review anddocument the differences between the UK and Norwegian sector legislation and regulations. This gapanalysis is available upon request from IMCA.

1.6 Status of the GuidanceThis guidance offers examples of good practice in the management of the transfer of diving operationsbetween the above named sectors.

1.7 Updating ArrangementsThis guidance is a dynamic document and the advice given in it will change with developments in theindustry. It is intended that this guidance will be periodically reviewed and any necessary changes orimprovements made.

Any person with suggested improvements is invited to forward these, in writing, to IMCA.

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2 Normative ReferencesA number of acts, regulations, guidelines and standards are referenced or have been used in the production ofthis document. In addition, the following listing contains documentation which can be used for further guidanceand information on the requirements of each sector. Industry standards and guidelines are included:

Norway

1 Regulations relating to Health, Safety & the Environment in the Petroleum Activities, 1 Jan 2002, issuedby the Norwegian Petroleum Directorate (NPD), the Norwegian Pollution Control Authority (SFT) andthe Norwegian Board of Health (NBH), commonly known as The Framework Regulations

2 NORSOK Standard U100 Manned Underwater Operations3 NORSOK Standard U101 Diving Respiratory Equipment4 NORSOK Standard J103 Marine OperationsUK

1 Health and Safety at Work etc. Act 1974 (HSWA)2 Diving at Work Regulations 1997, SI No.2776 known as DWR 973 Approved Code of Practice (ACoP) L103, Commercial Diving Projects Offshore relating to DWR 974 Diving Information Sheets (DVISs) issued by the UK HSEIMCA (incorporating DPVOA & AODC)

A full list of current IMCA guidance documents is available on the IMCA website www.imca-int.com

Diving Medical Advisory Committee (DMAC)

A full list of current DMAC guidance notes is available on the DMAC website www.dmac-diving.org or onthe IMCA website.

European Diving Technology Committee (EDTC)

A full list of EDTC documents is available from the EDTC website www.edtc.org

International Maritime Organization (IMO)

A468 Code on Noise Levels on Board Ships

A343 Recommendations on Methods for Measuring Noise Levels

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3 Administrative Requirements3.1 Organisation

Both sectors require that the companies have a system which ensures that the planning andperformance of the projects are carried out in a safe manner.

The NORSOK U100 requirement is more specific to that:

The contractors organisation shall include administrative functions responsible for areas that ensure a safeand efficient operation. As a minimum, these functions are: manned underwater operations; safety, healthand environment; emergency preparedness; quality; personnel; and management of diving equipmentincluding, if relevant, the work-site.

Guidance:

Verify that the management system and personnel requirements are in accordance with bothsector requirements.

3.2

Administrative Requirements

Both sectors require a system to make sure that the personnel working for the diving contractor fulfilthe regulations in the country in question

In Norway the responsibility remains with the operator. In the UK, the main responsibility rests withthe diving contractor. However, DWR 97 Regulation 4 places a duty to ensure compliance with theseregulations. It further places responsibility on other persons that are not members of the dive team,but may affect the safety of the dive team such as the client, the principle contractor, OIM, client'srepresentative, master and diving superintendent to ensure that the DWR regulations are compliedwith.

Guidance:

Establish a system which is able to fulfil this requirement for both countrys legislation

3.3 Management of ExceptionsA diving contractor should have within its management system a method of obtaining an exemptionfrom the relevant authority.

Guidance:

Norway: Any application for an exemption/deviation against a regulatory requirement has togo via the operator for further handling.

UK: The diving contractor may apply directly to HSE.

3.4 Application for Consent to DiveThe operator in Norway needs to obtain consent to dive from NPD before a manned underwateroperation can start, whereas this is not required in UK. However, the diving contractor needs to beregistered with the HSE in the UK.

Guidance:

Norway: The operator in Norway is responsible for the application for the consent to dive,whereas there is no requirement in the UK for an application for consent to dive. It isrecommended that for Norwegian diving operations the diving contractor obtains a copy ofthe consent to dive from the operator.

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3.5 DocumentationBoth sectors require that comprehensive documentation is prepared and utilised on the work site andrelevant to the work scope which is being performed.

In most aspects the requirements are identical and include:

normal and emergency operating procedures for the equipment;

checklists and similar verification documents to ensure that the equipment has been inspectedand is fit for purpose (such as IMCA D 023 and D 024 DESIGN Diving Equipment SystemsInspection Guidance Note documents);

risk analysis and assessment reports relating to the operation of the equipment and the worktasks being undertaken;

equipment maintenance system and reports;

equipment certification documentation;

bridging documentation between the diving contractors management systems and theoperators systems, specific to the work site and work scope to be undertaken.

Variations in documentation include the following:

3.5.1 ISO 9000The Norwegian legislation requires that the quality system should be based on ISO 9000system; this is not defined in the UK requirements.

Guidance:

Management systems and quality assurance should be implemented in accordancewith ref. 2.1 (ISO 9000 series Quality Systems Model for quality assurance in design,development, production, installation and servicing).

The diving contractor should establish a checklist for the management system toensure that the documentation required in Table 1 in NORSOK U 100 section 4.5 is inplace prior to commencing manned underwater operations in Norwegian waters.

3.5.2 Risk AssessmentBoth sectors have a requirement for risk assessment and the detailed requirements are laiddown in a number of different places within each of the sectors regulations.

Guidance:

Diving contractors need to have a system which ensures that regulatory requirementsfor risk assessment and contingency requirements are fulfilled in both sectors.

3.5.3 Job DescriptionsIn the Norwegian sector it is a requirement that detailed job descriptions are in place for allpersonnel categories involved in manned underwater operations (MUO) (ref. NORSOKU100 section 4.2). In the UK sector this is not a specific requirement.

Guidance:

Job descriptions forallcategories of personnel involved in MUO should be put in placeat the work site.

3.5.4 Diving TablesNorwegian Sector: When performing diving operations within the Norwegian sector, the

diving contractor has to ensure that diving and decompression procedures comply with thefollowing requirements:

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Saturation diving

NPD Report OD-91-12 Report regarding comparison of saturation diving tables and frameconditions for standardisation (ref. NORSOK U100 2.23)

Surface oriented diving

Norwegian Diving and Treatment Tables, ISBN: 82-992411-0-3 (ref. NORSOK U100 2.24)

UK Sector:

Saturation diving

In UK waters, diving contractors use in-house diving and decompression procedures.

Surface oriented diving

Maximum bottom times should be in accordance with HSE Diving Information Sheet No. 5 Exposure limits for air diving operations (ref. ACoP L103 paragraph 44).

Guidance:

The diving contractor should have a management system that caters for the differingsector requirements.

3.5.5 Compliance MeasurementPrior to performing diving operations in Norway it is required that an in-date compliancemeasurement with regards to the NORSOK U100 standard and relevant regulatoryrequirement should be available and any non-compliances forwarded to the operator foracceptance (ref. NORSOK U100 section 4.3).

Such a comprehensive compliance measurement is not specifically required in the UK sector.However, the diving contractor has the responsibility to ensure compliance with relevantregulatory requirements.

Guidance:

Compliance measurement documentation with regards to the NORSOK U100standard and relevant regulatory requirement should be put in place and maintainedup-to-date. Any non compliance in accordance with requirements needs to beforwarded to the operator in Norwegian sector.

Similar documentation should be put in place to verify compliance with the UK ACoP.

3.5.6 Divers CertificatesIn the UK sector it is a requirement under the ACoP that the divers have their originalcertificate in their possession at the work site. The Norwegian requirements do not specifythat the original certificate is held at the work site.

Guidance:

Divers in both sectors should always ensure that they have their original certificationwith them at the work site.

3.5.7 Document RetentionIn the 2002 NPD Information Regulations, section 4, a requirement has been imposed toretain the operation log relating to manned underwater operations (MUO) for a period of40 years. The UK ACoP requires that the diving operations record be retained for 2 years.

If a vessel moves between the sectors the operation log should be maintained for bothsectors as the information therein may be considered relevant at some point in the future

when considering the long term health effects on divers in saturation.

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Guidance:

The contents of Norwegian operations log have not been defined. It is recommendedthat, as a minimum, the diving contractor records the particulars to be included in thediving operation record (ref. Annex 1 of UK ACoP). For work in the Norwegian sector,the operations log should be retained for 40 years, in order to comply with therequirements of the NPD Information regulations section 4. For work in the UK sector,consideration should be given to the retention of diving operation record for a period

of 40 years.

3.6 ReportingIn both sectors the diving contractor is required to submit detailed reporting to the operator andregulatory authorities for all manned underwater operations (MUO). Such reporting should include:

Daily operations reports;

Accident/incident reports.

The following describes differences in reporting requirements between the sectors:

3.6.1 Monthly/Quarterly Activity ReportsIn Norway it is a requirement that a monthly activity report is submitted by the contractor tothe operator (ref. NORSOK U100 section 4.6.2.3). The content of this report puts a highemphasis on health and medical aspects of the previous months operations. The medicalaspects should be reviewed by the working environment committee at the work site. If avessel has transferred between sectors the monthly report is required to report all pertinentactivities, specifying abnormalities, technical and operational problems of relevance to thehealth or safety of the personnel, and detailing corrective actions taken, whether the activitieshave been performed whilst working in one or both sectors, or for multiple operators.

Quarterly activity reporting of manned underwater operations (MUO) the divingcontractor is required to report to the operator the MUO activities during each quarter of a

year, ten days after the quarter ends in accordance to form issued by NPD.

Guidance:

The diving contractor should prepare and submit monthly activity reports at the end ofeach calendar month to all operators for whom work has been performed in thatmonth, containing the information requested in NORSOK U100 section 4.6.2.3

3.6.2 Annual/Final Experience ReportsNORSOK U100 section 4.6.2.4 requires that an annual or final report be prepared andsubmitted to the operator within three weeks of the demobilisation or at the end of aseasonal campaign. The content of this report may have additional requirements over andabove the normal operators requirements in the UK sector, particularly in the medical andhealth related aspects.

Guidance:

The diving contractor should develop and implement standardised end-of-job reportingformat which meets the requirements of both operators/contractors as well as therequirements set out in the NORSOK U100 standard.

3.6.3 Accident/Near Accident/Incident Notification and ReportingIn both sectors the diving contractor is required to undertake and submit accident andincident reports with subsequent investigation and close-out reporting. In Norway theoperator is responsible for reporting to NPD. In the UK, where this is related to a diving

project the diving contractor is responsible for reporting to the HSE . The major differencebetween the reporting requirements of the two sectors is that in the Norwegian sector an

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ear infection is a reportable occupational illness, whereas in the UK sector such infections arenot reportable from the diving contractor to operator/regulatory bodies.

Guidance:

A standardised reporting format and content should be utilised in both sectors,including reporting of ear infections as medical events.

The investigation of accidents, near accident or incident needs to be in accordance

with each sectors requirements and the diving contractor should have thisrequirement in its management system.

3.7 Diving Contractors Contingency CentreNORSOK U100 states:

While in operation, the contractor shall maintain, in immediate readiness, a contingency room withadequate communication facilities, all relevant documentation and other necessary facilities for thecontingency team.

This is not specifically required in UK, though DWR 97 regulations 6 and 8 include a generalstatement that diving contractor should evaluate the the need for contingency systems.

Guidance:

The diving contractor should maintain such a contingency centre valid for both sectors.

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4 Health, Working Environment and Safety4.1 Health Organisation

The Diving Contractor is required to establish and maintain a Health Organisation to support hisoperations in both Sectors.

4.2 Medical EquipmentIn both sectors suitable medical equipment shall be provided at the work site. A description of suchmedical equipment and facilities is set out in DMAC 015 -Medical Equipment to be held at the Site of anOFFSHORE Diving Operation and DMAC 028 The Provision of Emergency Medical Care for Divers inSaturation.

4.3 Suitable DoctorsThe physiology of diving and the problems encountered by an ill or injured diver are not subjects

which most doctors understand in detail. For this reason it is necessary that any doctor who isinvolved in any way with examining divers or giving medical advice in relation to divers has sufficientknowledge and experience to do so.

The medical examiner of divers who certifies their fitness to dive needs to have an understanding ofthe working environment of the diver, which is normally gained by undertaking an appropriate trainingcourse. Such a doctor however may be unable to give the necessary advice in relation to treatment ofdecompression sickness or other diving related injury.

Some doctors, as a result of training and/or experience have the necessary knowledge to advise onsuitable treatment of diving related injury. They are usually described as diving medical physicians.

A consultant in diving medicine should be competent to manage the medical and physiological aspectsof complex diving activities. Such a doctor should have sufficient experience and training to advise thediving contractor concerning diving medicine issues.

In each sector these doctors need be registered and approved by the relevant authorities. As such, itis required that UK approved practitioners are utilised when working in the UK sector and Norwegianapproved practitioners when working in the Norwegian sector.

The Joint Medical Sub-committee of the European Committee of Hyperbaric Medicine (ECHM) andthe European Diving Technology Committee (EDTC) has prepared Training Standards for Diving andHyperbaric Medicinewhich cover competences for a number of different job functions in diving andhyperbaric medicine including the medical examiner of divers, the diving medicine physician and theconsultant in diving medicine.

4.4 Medical ChecksAll divers at work need have a valid certificate of medical fitness to dive issued by a suitable doctor.The certificate of medical fitness to dive need be renewed prior to expiry if a diver wishes to continuediving at work. If the examination is carried out during the last thirty days of the validity of thepreceding medical then the start date of the new certificate will be the expiry date of the oldcertificate.

The certificate of medical fitness to dive is a statement of the divers fitness to perform work underwater, and is valid for as long as the doctor certifies, up to a maximum of twelve months.

Guidance:

The diving contractor should check the diving medical certificates as restricted diving medicals

may be issued, restricting the maximum depth for the diver in question.Pre-dive medical checks are required for saturation exposure in both sectors. In Norway thereis a further requirement for a post-dive medical check for saturation exposure and for pre- andpost-dive medical checks for air diving exposure.

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A nurse is required to perform medical checks for pre- and post- diving exposure in theNorwegian sector or on divers who commenced exposure in the Norwegian sector and whosubsequently transferred to the UK sector.

4.5 Liaison with a Suitable DoctorFor manned underwater operations in Norwegian waters the diving contractor needs to have an

arrangement with a suitably qualified doctor who has the medical responsibility (the consultant indiving medicine). In addition to this the diving contractor shall have a duty doctor arrangement withsuitably qualified medical practitioners (diving medicine physicians).

Guidance:

The diving contractor should ensure that the consultant in diving medicine fulfils therequirements stated in NORSOK U100 5.1.2.2 Medical Responsibility and that the divingmedicine physicians that are under the duty doctor arrangement fulfils the requirements inNORSOK U100 5.1.2.4 Duty doctor arrangement and qualifications.

4.6 NurseA nurse is required to be present on the work site/DSV when manned underwater operations arebeing performed in Norwegian waters.

NPD Activities Regulations Section 6 states: On a facility, there shall be maintained at all times, asufficient number of nurses to ensure the adequate performance of the health service.

Guidance:

The diving contractor should ensure that a nurse with the required experience and training ispresent on the work site/DSV when performing manned underwater operations in Norwegianwaters.

4.7 Safety DelegatesIn Norway it is a requirement that safety delegates are elected by the work force on the work site/DSV. Such elected safety delegates are required to have undertaken safety delegate training(Arbeidsmilj kurs).

Guidance

The names of the safety delegates that are present at the work site/on board the vessel shouldbe displayed on a notice board. This information should also be given to personnel during theirwork site induction/project familiarisation.

4.8 Working Environment CommitteeIn the Norwegian sector a particular emphasis is put on the formation of a working environmentcommittee.

Members of the working environment committee include members of the onboard management teamand members elected by the work force. Members of the working environment committee arerequired to have undertaken safety delegate training (Arbeidsmilj kurs).

Whilst there is no direct equivalent within UK legislation, the vessels flag state will normally requirethat a safety committee is established onboard and meets regularly. This committee should comprisemembers of the onboard management team as well as representatives of the onboard departments,and serves a similar function to the working environment committee.

Guidance:

The roles of the onboard safety committee and the working environment committee should bemerged into one committee covering both functions, and this committee should be in placeand operational at all times as required under the Norwegian Working Environment Act. This

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will allow the committee to serve its required functions in either sector. it should also ensurethat members of the committee undergo the required safety delegate training in advance ofthe vessel transferring into the Norwegian sector (as the members should be given such trainingwhenever they are voted or appointed onto the committee).

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5 Personnel Qualification Requirements5.1 Familiarisation Process

In both sectors there are specific requirements in place to ensure that personnel are familiarised withthe diving equipment and relevant operating and emergency procedures (NORSOK U100 section 6.2

and ACoP paragraphs 84/85). A well documented familiarisation programme should fulfil therequirements for either sector.

However, in the Norwegian sector there are additional familiarisation requirements for the marinecrew where key marine crew members also need to be put through an in-house familiarisationprogramme covering diving operations.

Guidance:

Marine crew members in critical positions (such as Captain, DP Operators, Chief Engineer,Electrician and Crane Operator) should be familiarised with diving operations.

5.2 Training and CompetenceWhilst both sectors specify certain standards for the qualification and competence levels for membersof the dive team, there are certain additional requirements which differ between the sectors. IMCAhas, through its members, implemented a competency scheme which will ensure that personnelinvolved in diving operations/manned underwater operations (MUO) are competent to perform theirassigned duties.

Variations which have to be considered are:

5.2.1 Safety Delegate TrainingIn Norway safety delegates are required to have undertaken safety delegate training(Arbeidsmilj kurs). Such safety delegate training should also be undertaken by designated

Supervisory personnel who have positions of responsibility during the operation, including butnot limited to:

Vessel master

Offshore manager/diving superintendent

Diving supervisors

Life support supervisors

Chief engineer

Chief officer/night master

Catering manager

Elected safety delegates

5.2.2 Diving SuperintendentUnder the NORSOK U100 standard, section 6.3.1, specific requirements are set out for thediving superintendent which include requirements over and above those specified in theACoP; namely that the diving superintendent needs to:

Have a minimum of two years technical or administrative education, or similar level ofcareer development

Have completed an introductory DP course this can be undertaken onboard thevessel using an in-house course.

Guidance:

Diving superintendents who may work in both sectors should be qualified as requiredby NORSOK U100 section 6.3.1

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5.2.3 Diving SupervisorUnder the NORSOK U100 standard, section 6.3.2, specific requirements are set out for thediving supervisor which include requirements over and above those specified in the ACoP;namely that the diving supervisor needs to:

Have completed an introductory DP course (if the vessel operates from DP) this canbe undertaken onboard the vessel using an in house course.

Have completed an advanced first aid course (diver medic). There is no specificrequirement for refresher training.

Guidance:

Diving supervisors who may work in both sectors should be qualified as required byNORSOK U100 section 6.3.2

5.2.4 DiversIn both sectors divers need to hold an approved diving qualification suitable for the work theywill be undertaking. In the UK HSE has a list of approved qualifications which is available ontheir website. NPD accepts the qualifications included on the HSE list apart form the HSE

Surface Supplied (with offshore top-up) certificate.

NORSOK U100 sets out training that divers need to cover which includes diving with selfcontained underwater breathing apparatus (SCUBA). When HSE revised its trainingrequirements in 1998, it removed the requirement for training in the use of SCUBA for thesurface supplied diver training. However in practice UK schools have continued to provideSCUBA training to their students on commercial air diving courses.

Guidance:

When working in Norway divers certification should be checked to ensure that SCUBAtraining has been covered as part of the surface supplied diver training course.

5.2.5

Divers in Saturation

The principal difference between the sectors is in the requirements for advanced first aid(diver medic) training.

In Norway it is specified that 80% of the divers in saturation should have such training, with aminimum of two divers at each level of saturation being qualified (NORSOK U100 section6.3.5)

In the UK it is required that at least one person in the dive team, other than the diver in thewater, should be qualified to a diver medic standard (ACoP paragraph 120). However theUK ACoP also requires that divers holding this qualification complete a refresher trainingcourse every three years.

These differences mean that there could be differing numbers or percentages of suitablyqualified divers in saturation between sectors

Guidance:

It is recommended that alldivers in saturation complete an advanced first aid (divermedic) course and hold an in-date advanced first aid (diver medic) certificate.

5.2.6 Life Support Supervisor and Life Support TechnicianUnder NORSOK U100 there is a specific requirement that life support supervisors (LSSs)and life support technicians (LSTs) need to have completed an advanced first aid (divermedic) course. However there is no requirement for refresher training.

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Guidance:

LSSs and LSTs who may work in both sectors should be qualified as required byNORSOK U100 section 6.

5.2.7 All PersonnelAll personnel who work offshore as their main area of employment are required to hold

appropriate Offshore Survival certificate and Offshore Medical. There are, however,differences in the required courses or examinations between the two Sectors.

Guidance:

All diving and project personnel should hold appropriate combined UK/Norwayoffshore survival certificates and appropriate medical certificates.

5.2.8 Periods of StayThe 2002 NPD Framework Regulations section 52 set out durations for periods of stayonboard the vessel (guidance on saturation period is covered in section 7 of this document)in Norwegian Sector. The regulations stipulate a 14 day duration with a seven day extension

permissible after consultation with the employees representative. Further extensions can beagreed by the NPD via the operator. Marine crew members are exempt from theseguidelines.

This can be a particular issue when a vessel is transferring from the UK sector to theNorwegian sector as the personnel onboard may have already exceeded the 21 days period,as there is no similar ruling in the UK sector. Such personnel may be on regular 28 days on/28 days off rota for example in which case their qualified and competent relief may not beavailable for a further period of time.

Guidance:

When a vessel moves from UK to Norway the maximum number of days allowedonboard is 14 days plus extension as agreed onboard of up to 21 days and the time

starts from entering the Norwegian sector, but if personnel have been onboard forexample 21 of their 28 days in the UK sector then the maximum stay onboard is up toa further 7 days.

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6 Technical Requirements6.1 Diving Equipment - General

The dive system installed on a DSV or other diving platform is required to be manufactured, installed,tested and maintained to acceptable standards. These are normally achieved by a variety of means

including class society survey during manufacture and operation; self audit and third party auditsagainst industry guidelines such as the IMCA D 023 and D 024 DESIGN documents; complianceverification documentation, etc.

There are, however, certain technical requirements set out in NORSOK U100 that differ from theclass requirements and IMCA (industry) guidance. The UK ACoP generally offers limited guidance inthe technical aspects as it relies on industry guidance and class requirements to detail suchrequirements.

A compliance verification report will ensure that a dive system and diving equipment will comply orwill highlight non-compliance areas. The following gives some detail of these differences:

6.1.1 Physical Work EnvironmentNORSOK U100 section 5.2.2 sets out the requirements for control of the physical workenvironment for divers in the chambers, bell, in water etc. These requirements cover aspectssuch as temperature (thermal control and balance); humidity; lighting; noise; radiation, andgives detailed requirements for each aspect which shall be met.

Guidance:

An evaluation and upgrade as required should be performed of the equipment forthermal balance during normal operations for divers in water, chambers, bells,monobaric craft and/or habitats

An acceptable means of humidity control to maintain humidity levels between 40%and 60% relative humidity should be verified.

Lighting levels within chambers and bells should be reviewed, documented and upgradeif required, and this should include the facility to adjust the light to a comfortablelevel

The noise levels within the diving area (outer and inner areas) in operationalconditions should be measured and documented and should be rectified if outwith thelimits set out in NORSOK U100.

6.1.2 Ergonomic DesignSection 19 of the NPD Facilities Regulations sets out the required standard in Norway for theergonomic design of work areas and work equipment. The UK Sector does not specify arequirement for ergonomic design assessments to be performed.

Guidance:

Documentation/records should be in place to verify that ergonomic assessments of thework place and work equipment have been undertaken, relating both to the supportvessel and the diving equipment.

6.1.3 Chemical Work EnvironmentNORSOK U100 section 5.2.3 sets out the requirements for control of the chemical workenvironment for divers in the chambers, bell, in water etc. These requirements include:

a documented system to ensure that all materials used in chambers, bells or breathingsystems etc do not produce harmful gases or vapours;

requirements for analysis of the breathing gas in relevant systems on a periodic basis

information on limits for gas composition in breathing systems

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Guidance:

A documented review of materials used in chambers, bells or breathing systems shouldbe undertaken.

A regular analysis of breathing gas within the hyperbaric chambers, bells and breathingsystems should be undertaken and documented. The analysis should cover all theparameters specified in NORSOK U100 standard.

The exposure levels for CO2 in the diving contractors diving manuals should complywith levels set out in the NORSOK standard.

CO exposure levels should be kept to the lowest possible levels and that the divingcontractors diving/health manuals should include advice on the symptoms and first aidtreatment procedures for CO poisoning.

6.1.4 Chamber DimensionsNORSOK U100 section 7.2.2 specifies that chamber height should be no less than 200 cmover the deck plates (measured in the middle of the chamber) and the inner volume shouldbe at least 4m3 per person (usable space which may be distributed between living, sleepingand TUP compartments)

Guidance:

The chamber dimensions should comply with NORSOK requirements.

6.1.5 Chamber BunksNORSOK U100 section 7.2.2 specifies that chamber bunks need to have a minimumdimension of 200 cm x 70 cm

Guidance:

Bunks within chambers should comply with the required NORSOK dimensions.

6.1.6 Chamber Gas SuppliesIn NORSOK U100 section 7.5 it states There shall be two independent sources of gas supply toeach section of a chamber complex where people may be staying if the sections can be isolated bypressure. This requirement is not specified within the UK ACoP.

Guidance:

Two independent gas supplies need to be provided to each compartment of thesaturation chamber complex.

6.1.7 Surface Orientated Diving ChambersNORSOK U100 section 7.2.3 specifies that surface orientated diving chambers should have a

minimum inside diameter of 180 cm and be at least 200 cm long.

Guidance:

The surface orientated diving chamber should meet the required dimensions set out inNORSOK.

6.1.8 Diving Bell ErgonomicsNORSOK U100 section 7.2.4.1 specifies that the diving bell shall have an inner volume of atleast 4.5 m3 for 2 divers plus an additional 1.5 m3 per diver in excess of two. In addition itrequires the tunnel for entry and exit to have a minimum of 80 cm inside diameter.

Guidance:Diving bells should be of sufficient volume and have an 80cm inside diameter accesstrunk to meet the requirements of NORSOK.

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6.1.9 Diving Bell SupplyThe UK ACoP para 126 specifies that the divers breathing gas supplies shall include independentprimary and secondary supplies.

NORSOK U100 section 7.5 specifies that two independent supplies are required to the gaspanel supplying the gas to the main umbilical. One supply shall be dedicated as emergency supplyand shall be activated if the downstream gas analyser to the diver gives an alarm signal and/or the

supply pressure drops below set values. The pre-set pressure on the emergency gas supply shall belower than the main supply.

Guidance:

The divers breathing gas supplies should have independent primary and secondarysupplies which comply with the above requirements.

6.1.10 Onboard Gas SupplyNORSOK U100 section 7.2.4.2 specifies that the minimum onboard gas supplies capacityshall be 1250 usable litres of breathing gas for each diver, calculated to the ambient pressure(equals 20 minutes at a breathing rate of 62.5 l/min). Section 7.5 also states The bell-man shall

have easy access to operate the gas panel in the diving bell. It is recommended that no more thantwo operations shall be required in order to activate the spare onboard gas supply in the event of afailure in the main supply

Guidance:

The onboard gas supplies should be sufficient for the required working depth at theconsumption figure of 62.5 l/min.

The bell onboard gas panel should comply with the NORSOK requirements.

6.1.11 Emergency Connectors for Bells, Habitats and HRVsIn both sectors bells, habitats and HRVs are required to have an emergency connector panel

in accordance with IMO requirements. However, in Norway NORSOK U100 section 7.2.4.3specifies that they should also be fitted with connectors in accordance with the (nowwithdrawn) NPD guidelines relating to manned underwater operations.

Guidance:

Connector panels on bells, habitats and HRVs should be in accordance with previousNPD guidelines and IMO GUIDELINES.

6.1.12 Alternative Handling SystemIn the Norwegian sector, each bell should have an alternative handling system which has thecapability to bring the bell back to the surface and to a position to be connected to the

chamber complex in case of a failure of the main handling system. In the UK sector it is notspecified that the bell needs to be brought back to the mating position, though IMCA D 024DESIGN specifies that a secondary means of recovering the diving bell to the surface,bringing it on board and mating it to the chamber system should be provided.

Guidance:

An alternative handling system should be is in place and fully tested which is capableof bringing the bell back to the chamber complex in case of a failure of the primarysystem components.

6.1.13 Breathing ApparatusIn Norway, breathing apparatus used in manned underwater operations (MUO) is required to

comply with the requirements of NORSOK U101 Diving Respiratory Equipment. The averageconsumption figures utilised in this standard exceed those set out in IMCA guidance and, as

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such, impact on several aspects of the diving equipment and operation. The NORSOKstandard requires that:

Breathing apparatus (masks and helmets used by divers underwater) be designed andtested for an average consumption of 62.5 l/min

Emergency gas supplies (bell bottles and bailout systems) are be able to providesufficient gas as specified elsewhere in the NORSOK U100 standard using theconsumption figure of 62.5 l/min.

Guidance:

Breathing equipment utilised should have been type tested and approved for use underthe NORSOK U101 Standard.

The capacity of onboard gas supplies should be verified for the required flow rates atthe working depth.

6.1.14 Gas Supplies to Breathing ApparatusNORSOK U100 section 7.8.1. requires that breathing apparatus fulfils the requirements ofNORSOK U101. In this standard (section 4.1) it is required that an evaluation is undertaken

to verify that the total gas supply system to breathing apparatus can supply sufficient gas tothe various masks, BIBS, etc.

Guidance:

An evaluation should be undertaken to verify the capability of the breathing gassupply system to supply sufficient gas to the breathing apparatus.

6.1.15 Communications SystemsIn the Norwegian Sector it is a requirement (NORSOK U100 section 7.13) that thecommunications system for divers in both water and hyperbaric chambers should have beentested for intelligibility, using a modified rhyme test and to fulfil the requirements foroperational communications systems in accordance with the relevant military standard MIL-

STD-1472.

Guidance:

Documented evidence should be provided of type testing or site testing ofcommunications equipment against the military standard.

A further requirement of NORSOK U100 section 13 is that Switching of communicationchannels shall be possible so that all persons who need to communicate have the possibility to do so;uninterrupted and independent of other communication channels. The panel containing thecommunication system shall be arranged in a logical and ergonomic manner. A traffic flow matrix ofthe system shall be documented and available on board.

Guidance:

A traffic flow matrix for the communications system should be documented whichshows how the requirements set out above are complied with.

NORSOK U100 section 7.13 also states Two independent main systems shall be installed forefficient communication between personnel engaged in manned underwater operations (MUO) andthe dive operation control room. An alternative facility for communication between personnel workingbelow surface and the operation management shall also be provided. This facility shall beindependent of the main communication systems. In the UK sector the required standard (asset out in IMCA D 024 section 2.2.2) is that Two way voice communications with each diver andthe standby diver (bellman) must exist. These facilities should be fitted with a back up power source,such as batteries.

Guidance:There should be two independent main communication systems installed betweenpersonnel engaged in MUO and the diving control room.

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6.1.16 Fire ProtectionIn the NPD Facilities Regulations section 36 it is required that hyperbaric chambers areprotected internally by a fixed fire fighting system which can be activated externally.

Guidance:

Saturation chambers should be equipped with an externally activated fire fighting

system (normally a water deluge system). Portable extinguishers will not be acceptedas a part of this system as they cannot be activated from outside the chamber.

6.1.17 Water SuppliesIn NORSOK U100 section 7.16 specific requirements for the treatment of both potablewater for the divers in the chambers and also for the treatment of divers water for suitheating are set out. Such treatments involve both disinfecting and/or filtration of the watersupplies and requirements for periodic examination thereof.

Guidance:

Water treatment systems for potable water should be provided for use in the divingsystem and for the divers suit hot water.

Periodic examination and testing of such water systems should be undertaken and theresults documented.

6.2 Maintenance and Certification SystemsBoth sectors require that plant and equipment used to support manned underwater operations ismaintained in a safe working condition. There are, however, differences between the sectors on howthe maintenance system is administered.

6.2.1 Maintenance EffectivenessThe NPD Activities Regulations, section 46, states The effectiveness of the maintenance shall beevaluated systematically on the basis of recorded data for performance and technical condition inrespect of facilities or parts thereof. The UK ACoP does not state the requirement forevaluating maintenance effectiveness.

Guidance:

Any maintenance system utilised should be evaluated within pre-set parameters todetermine the effectiveness of the system.

6.2.2 Maintenance ClassificationSection 43 of the NPD Activities Regulations sets out a requirement for systems andequipment to be classified with regard to health, environment and safety relatedconsequences of potential failures. It further states that this classification will constitute thebasis for maintenance activities and maintenance frequency, and for the priority of differentmaintenance activities.

Guidance:

The maintenance system in place for the plant and equipment for manned underwateroperations (MUO) should classify and prioritise maintenance tasks with regard tohealth, environment and safety related consequences of potential failure.

6.2.3 Certification of Loose Lifting EquipmentIn both sectors there is a requirement that lifting appliances and lifting gear are inspected,

tested and certified in accordance with the national legislation in each sector. There is,however, a difference between the two sectors in the period between such inspection,testing and certification; namely six months in the UK sector and 12 months in theNorwegian sector.

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Guidance:

The inspection, testing and certification regime is in place should satisfy the sectorlegislation.

6.3 Support VesselMost saturation diving operations which take place in both sectors does so from dynamicallypositioned (DP) diving support vessels (DSVs). These vessels are generally classed with one of themajor classification societies with a DP Class notation and, in the case of vessels built since 1994,issued with an IMO equipment class FSVAD (flag state verification acceptance document). There areidentified differences between the two sectors relating to operations from DP vessels and othergeneral differences relating to the support vessel.

6.3.1 DP OperationsDP support vessels can be categorised under the IMO guidelines as one of the following:

Equipment Class 1 equivalent to DNV DP Class AUT, LR DP Class DP (A), ABSDPS-1

Equipment Class 2 - equivalent to DNV DP Class AUTR, LR DP Class DP (AA), ABSDPS-2

Equipment Class 3 - equivalent to DNV DP Class AUTRO, LR DP Class DP (AAA),ABS DPS-3

In the UK ACoP para 58 it states Diving from dynamically positioned vessels can be hazardous todivers and para 59 states Any vessel operating on dynamic positioning should meetindustry technical and operational standards. However the ACoP is not prescriptive aboutwhich Class of DP vessel is utilised for the support of diving operations; it relies on thediving project plan and associated risk assessment to determine the appropriate DP Classfor the support vessel.

In Norway the selection of DP support vessel Class is more prescriptive. The guidelines tothe NPD Activities Regulations section 81 states Manned underwater operations where loss ofposition entails a high risk for divers or diver platforms Equipment Class 3 and Mannedunderwater operations where loss of position entails risk for divers or diver platforms EquipmentClass 2. In addition, the NORSOK J003 Marine Operations Standard states Manned Subseaoperations Class 3 for diving inside structures etc. and Manned Subsea operations Class 2 fordiving in open water.

Guidance:

The selected DP support vessel should be suitably classed and operated appropriatelyfor the operations to be undertaken.

6.3.2 Portable Electrical Power ToolsIn the UK sector under the HSW Act and supporting regulations it is a requirement thatportable electrical power tools used in damp areas and on deck are 110V supply. This is nota requirement in the Norwegian sector, where typically 220/240V supplied power tools areused.

Guidance:

All deck power tools should be fed from 110V supplies.

6.3.3 Noise LevelsOnboard support vessels there are requirements to provide noise protection equipment in

areas of high noise. However, the pre-set levels at which such equipment should be provideddiffers between the sectors in the UK the limit is 90 dB (A) and in Norway it is 83 dB (A).

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Noise requirements for vessels are set out in IMO A468 Code on Noise Levels on Board Shipsand A343 Recommendations on Methods for Measuring Noise Levels.

Norwegian Sector: NPD Facilities Regulations Section 22 define noise that is harmful tohearing as By noise that is harmful to hearing is meant a daily noise exposure which in the courseof a workshift exceeds a twelve-hour equivalent sound level of 83 dB(A), or an impulsive sound levelof Lpeak=130 dB(C).

Noise levels for manned underwater requirements are considerably less than 83 dB(A).guidelines to Section 22 of NPD Facilities Regulations states in order to fulfil the requirement tonoise, the NORSOK U100 standard section 5.2.2.5 should be used for manned underwateroperations.

The requirements given in NORSOK U100 section 5.2.2.5 are:

Sleeping chambers 60 dB(A)Living chambers 65 dB(A)Control room 65 dB(A)Diving bell 65 dB(A)*Habitats 65 dB(A)*diver in water 70 dB(A)

*Does not include self induced noise.

UK Sector: In the UK waters noise levels are set out in the Offshore Electricity and NoiseRegulations 1997. These regulations make the Noise at Work Regulations 1989 applicablefor work offshore. The requirement in the Noise at Work Regulations 1989 are:

the first action level means a daily personal noise exposure of 85 dB(A);the peak action level means a level of peak sound pressure of 200 pascals;the second action level means a daily personal noise exposure of 90 dB(A).

Where the noise exposure is above the first action level but less than the second action levelemployees should, at their request, be provided with suitable and efficient ear protectors.

Where the noise exposure exceeds the second action level employees need to be provided

with suitable personal ear protectors.

Guidance:

All personnel working in areas where the ambient noise levels exceed 83 dB should beprovided with suitable noise protection equipment.

Where noise levels exceed requirements given in NORSOK U100 all practical effortsneed to be made to reduce the noise to an acceptable level on existing vessels.

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7 Operational RequirementsThis section refers to the regional requirements and differences for the safe performance of mannedunderwater operations (which are not addressed elsewhere in this document).

7.1 Numbers of Personnel/Team SizeIn general the two sectors follow similar requirements for numbers of personnel and team sizes, asdescribed in the following references:

UK Sector: In the UK sector the number of personnel/team size need to comply with the ACoP andfollow the guidance set out in information note IMCA D 28/98 Minimum Supervisory Requirements forOffshore Diving Operations Carried Out on the UK Continental Shelf, this allows one supervisor within thecontrol room and the other within close proximity of the control room.

Norwegian Sector: Requirements on dive team size are set out in the NORSOK U100 standard.In section 8.5.1, namely in the manning of control rooms it is specified that there need to be at leasttwo qualified persons present in a control room (both saturation control and dive control) during allphases of the work. For short periods (such as meal breaks) one of the qualified persons may be

replaced by a competent person. In addition there is a requirement for a nominated gasman to beincluded in the dive team.

Guidance:

A gasman should be provided on board for Norwegian operations. The control room should beadequately supervised in accordance with the sector requirements.

7.2 Working Periods/Time Provisions7.2.1 UK Sector

The following guidance set out in IMCA D 014 IMCA International Code of Practice for Offshore

Divingdescribes the UK requirements for working periods relating to diving operations:

It is recognised that long hours are sometimes required, but such circumstances should beexceptional and never planned. It should be remembered that accidents are more likely whenpersonnel work long hours because their concentration and efficiency deteriorate and theirsafety awareness is reduced.

Work should be planned so that each person is normally asked to work for a maximum of 12continuous hours, and is then given a 12-hour unbroken rest period between shifts.

Members of the diving team will not be asked to work for more than 12 hours without havingat least 8 hours of unbroken rest during the previous 24 hours. Similarly, the longest period aperson will be asked to work, and only in exceptional circumstances, will be 24 hours before

being given 8 hours unbroken rest. This may be, for example, where a diving team has been onstandby, but not diving, for a number of hours before diving is needed. In such cases, extremecare will need to be taken and allowance will need to be made for the effects of fatigue.

In saturation diving, the divers will not be asked to undertake a bell run exceeding 8 hours fromseal to seal. They will then need to be allowed at least 12 hours of unbroken rest.

Extended work periods offshore without a break can reduce safety awareness. Work willtherefore need to be planned so that personnel do not work offshore for long periods withoutbeing allowed time onshore. These times may need to vary to suit operational needs orexceptional circumstances, but personnel should be given a reasonable onshore break related tothe period spent offshore.

No person will be expected to work a 12-hour shift without a meal break taken away from theirplace of work. Personnel also need toilet and refreshment breaks during their shifts.

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To allow for these breaks, the diving contractor will need to ensure that the planned work eitherhas natural breaks (for example, during periods of strong tide) or that qualified and experiencedpersonnel are available to act as reliefs during breaks. This is particularly important in relationto supervisors whose responsibilities are often onerous and stressful. Any such handovers ofresponsibility should be recorded in writing in the operations log.

7.2.2 Norwegian SectorNORSOK U100 section 8.4 sets out the following requirements relating to time provisions:

Stay at working depth:

During saturation diving stay at working depth shall not exceed 14 days. For diving deeperthan 250 msw this stay shall not exceed 10 days.

The planning shall take into consideration the strain that the divers will be exposed toduring the operation when the time period for stay at working depth is determined. Thestrain on the divers shall be continuously considered during the operation with regard towhether a shorter period should be applied. It is a prerequisite that the total length of stayunder pressure is the subject of discussions with the representatives of the personnelincluding safety delegates.

In addition, Activity regulation section 85 g) work free period for work underincreased pressure states:

Divers working in water or working or under increased ambient pressure shall in thecourse of a twenty-four hour period have a continuous work free period of at least 12hours. Work and rest periods shall be specified in a shift program and shall be planned atregular hours.

Time between saturation periods

NORSOK U100 section 8.4.2 states The time between saturation periods shall at leastbe equal to the duration of the preceding saturation period. In the case of diving deeperthan 250 msw the time between saturation periods shall be at least twice the duration ofthe last saturation period.

Bell run

NORSOK U100 section 8.4.3 states Maximum time for a bell run is 8 hours forordinary saturation diving, and 6 hours for diving deeper than 200 msw. Workloads shallbe assessed during planning of the diving operations, and if applicable a shorter bell runmay be chosen. If the divers request that the dive should be suspended before themaximum permissible time is up, this shall be decisive. Timing of bell run duration startswhen the clamp is first taken off.

Time in water

NORSOK U100 section 8.4.4 states Continuous time in water during a 12-hour periodshall not exceed 4 hours. For diving deeper than 200 msw this shall not exceed 3 hours.

Provisions relating to time on breathing masks

The following provisions relating to time periods also apply with regard to mannedunderwater operations:

e) use of breathing mask:

after a maximum of 4 hours, divers using breathing mask in the submerged habitat shallhave a rest period in an atmosphere that does not require the use of a breathing mask

Supervisor in direct communication with divers in water

Surface personnel in direct communication with divers in the water should not havethis function for more than 4 consecutive hours without a break. Total time for this

function should be limited upwards to 8 hours in the course of a twelve-hour period.

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7.3 General7.3.1 Umbilical Management

In both sectors an umbilical management system is required. However, in the Norwegiansector a standardised umbilical marking system needs to be utilised (NORSOK U100section 7.9).

Guidance:

The standardised Norwegian umbilical marking methodology across both sectorsshould be followed.

In the UK sector there is no specific limitation on the length of divers umbilicals thelimitations are set by practical limitations (umbilical storage etc) as well as by operationalconstraints (distance to nearest hazard for example). However in Norway U100 sets a limitfor the length of the working divers umbilical to 45m (for normal operations).

Guidance:

When working in Norway, working divers umbilicals should be restricted to 45m lengthand that the work is planned around this restriction.

In both sectors the working divers umbilical length needs be restricted to ensure that thediver can maintain a distance from the nearest hazard (e.g. thrusters, water intakes etc) of5m. In the UK the distance from the nearest obstruction for determining the length of thestandby divers umbilical is 3m, whereas in Norway the distance is 2m.

Guidance:

In both sectors the UK guidance of maintaining 5m and 3m respective distances fromthe nearest hazard for the working diver(s) and standby diver should be followed.

7.3.2 Saturation Duration LimitationsDue to the differing requirements set out in the UK ACoP and in the NPD 2002 Regulationsconcerning time limits for divers in saturation, the following guidance is given relating to themanagement of this matter when transferring a DSV from the UK sector to Norwegiansector with divers in saturation. The operator in the Norwegian sector has responsibility forthe divers until successful completion of the bend watch.

Guidance:

When transferring from the Norwegian Sector to the UK Sector the 28 days maximumduration as set out in the ACoP 82 will apply.

Responsibility for the divers through to the completion of the bend watch maybe delegated in writing to the Diving Contractor by the Operator. This shouldinclude details of the continuing work scope and diving tables to be used. The

intention to undertake this action should be highlighted in the consent to diveapplication by the Operator.

Divers may transfer from the UK sector to the Norwegian sector on the basis that theycan comply with the following provisos:

A time limit for personnel involved in manned underwater operations on board avessel in Norwegian waters is 21 days maximum.

For divers in saturation when depth is less than 250 meters: 14 days bottom +decompression + bend watch must not exceed 21 days

For divers in saturation when depth is more than 250 meters: 10 days bottom +decompression + bend watch must not exceed 21 days (This scenario unlikely tooccur when transiting from a UK diving operation).

With the above in mind, the following should be taken into account when a vessel withdivers in saturation enters Norwegian waters from UK waters to perform mannedunderwater operations:

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Divers that have been in saturation for 21 days or more - decompress inaccordance with UK procedures.

Divers in saturation whose time in saturation + decompression time + 24 hourbend watch is more than 21 days - decompress in accordance with UKprocedures.

Divers in saturation whose time in saturation + decompression time + 24 hourbend watch is less than 21 days - This saturation would be allowed to continueafter an appropriate stabilisation period had been completed and transferredover to the Norwegian tables. The stabilisation period would be determined bythe company diving medical adviser (a diving medical physician or consultant indiving medicine (see section 4.3)) and would take into account any previousexcursion penalties that would influence this stabilisation period. An example isa total stay of 21 days on board starting when these divers where blown down;i.e. 14 / 10 day bottom time + decompression + completion of bend watch anddeparting the vessel shall not exceed 21 days.

7.3.3 Monitoring SystemsNORSOK U100 section 8.3.2 sets out requirements for on-line monitoring and recording ofdiver, chamber, bell, habitat and ADS parameters.

Further additional parameters should also be monitored and recorded during deep divingoperations (beyond 200msw).

Guidance:

To comply with these requirements an on-line monitoring and recording system shouldbe installed and integrated into the relevant sensors and instrumentation.

7.3.4 Diving TablesIn the UK Sector the ACoP does not specify compression rates, excursion limits ordecompression rates, etc. (information commonly contained in diving tables). It is theresponsibility of the diving contractor to provide such information to the personnel at thework site and to verify that the use of such tables will not be detrimental to the health orsafety of the divers.

In the Norwegian sector there are certain constraints imposed which entail having Norway-specific diving tables for use by the diving contractor and his personnel. The use of the UKor other diving tables may not comply with these constraints.

Guidance:

When undertaking manned underwater operations (MUO) in Norway approvedNorwegian diving tables should be used. When undertaking MUO in the UK the

contractors approved diving tables may be utilised these may also be Norwegiantables, but when moving between tables the company diving medical adviser (a divingmedical physician or consultant in diving medicine (see section 4.3)) should beconsulted.

7.3.5 Weather LimitationsNORSOK U100 section 9.1.2 states that Operations shall not be performed in sea - statesexceeding 90% of the systems capacity. In the UK sector, ACoP para 153 states that a plantregister should be maintained on board and that this register should contain details of anydesign limitations such as weather.

Guidance:

The weather limitations of the system need to be known and documented. In Norwayoperations should cease at 90% of the maximum operational sea state.

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7.3.6 Bend WatchUK references DMAC 07 Recommendations for Flying After Diving for guidance on bendwatch duration where as Norway has a mandatory 24 hours bend watch.

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8 Emergency and Contingency Equipment8.1 Hyperbaric Evacuation

Although both sectors set out requirements for the provision of hyperbaric evacuation systems, thereare additional requirements in place in the Norwegian sector as follows:

In Norway the diving contractors plan for hyperbaric evacuation should be based on risk analysescovering the launch, stabilisation, recovery and normalisation phases of an evacuation and thefollowing phases should be described in the contingency plan:

i) Transfer of divers to the evacuation unit, and launching of the unit;ii) The evacuation unit in the water, including a description of how the life support functions are

planned to be maintained, where and how the rescue unit is to be moved and, if applicable,taken out of the water;

iii) Evacuation unit taken under control and decompression of diversGuidance:

A hyperbaric contingency plan should be established which fulfils the requirements for bothsectors. In addition the diving contractor should document:

a) the time taken from the moment the last diver enters the evacuation unit to the unit being100 metres away from the mother vessel/worksite is less than 15 minutes;

b) the total time period from notification of evacuation, with divers in the chamber complexuntil the time the evacuation unit is 100 meters away from the mother vessel/worksiteshould not exceed 30 minutes.

This time includes the time required to equalise the system, should there be a split levelsaturation and or decompression ongoing, to enable transfer of all divers into the evacuationunit.

8.1.1 Pressure DifferentialIn NORSOK U100 section 9.3.2 it is required that, if there are more than 18 Bars pressuredifferential between persons who are to be evacuated, it should be possible to maintain adifference in pressure during evacuation.

Guidance:

The NORSOK requirement only be achieved in practice by the following methods:

Having a Twinlock evacuation system

Having two hyperbaric evacuation systems

Maintaining the persons in saturation with less than 18 Bar pressure differential

8.1.2 Recovery SystemsIn the 2002 NPD Facilities Regulations section 43 it is required that Hyperbaric EvacuationSystems shall be designed so that they can be towed and lifted out of the water in the weatherconditions relevant to the use of such lifeboats. An evaluation of the towing arrangements andrecovery arrangements is required to verify how this requirement is met. At present thereare practical restrictions in complying with this regulation and current (at time of issue of thisdocument) practice is to apply for an exemption from NPD.

Guidance:

An evaluation to determine the maximum weather limitations for recovery of ahyperbaric evacuation system should have been undertaken and that these limits

should be documented and understood by all relevant parties

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A towing evaluation should have been performed and documented and that relevantinformation on the towing characteristics and limitations of the hyperbaric evacuationsystem should understood and available to all relevant parties

8.1.3 Hyperbaric Evacuation SystemIn the UK ACoP it is required that a hyperbaric evacuation system is provided for the divers

in saturation, and that this system needs to have life support for 24 hours (ACoP para 67).

In Norway such a system is also required, however there are additional requirementsimposed in NORSOK U100 section 7.4:

The HRV shall be capable of maintaining an acceptable environment for 72 hours, includinga facility to provide such service even if the HRV primary power supply is unavailable

Guidance:

The capability of the HRV to provide an acceptable environmental control for72 hours (refer to new IMCA information note on the thermal testing ofhyperbaric evacuation systems) should be verified and documented.

The HRV shall have its own propulsion facility, which shall be capable of functioning for atleast 72 hours. It shall be reasonably powered and strengthened for its size and mass whenfully equipped and manned. It shall further contain equipment for oral communication withother craft, e.g. a two way marine VHF radiotelephone

Guidance:

The HRV's propulsion needs to be able to function for a minimum of 72 hoursand should be equipped with the relevant communications equipment. Thisshould be documented.

NORSOK also requires that the HRV is equipped with an O2 connection point. Thisis in addition to the connectors mentioned in section 6.1.11 of this guidancedocument.

Guidance:

The HRV should be equipped with an O2 connection point

NORSOK requires that the HRV has a facility for the chamber occupants to controlthe O2 make up and gas supply in case of the crew having to leave the HRV

Guidance:

The chamber occupants should be able to take control of O2 and gas supplies ifrequired.

NORSOK requires that a life support package (LSP) is provided at a suitable location

where it can reach the HRV in a reasonable time.

Guidance:

The LSP availability should be documented within project/DSV contingencyplans.

In addition, the NPD Facilities Regulation section 43 requires that an HRV can be lifted out ofthe water by a single anchorage point.

Guidance:

The HRV should be able to be recovered by a single point lift, typically a suitable 2 legsling arrangement which is permanently installed on the HRV.

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8.2 HabitatsThe UK ACoP is non-specific about the use of habitats for support or performance of underwateroperations, however survival times for divers in Habitats is taken to be 24 hours in the UK Sector(treated as for survival times in a bell); in NORSOK U100 section 7.2.8 a habitat must be equipped tomaintain vital functions for a minimum of 48 hours, when primary supplies are not available, and have anoutside panel for emergency connections including gas, heat and communication.

In addition the same section of the NORSOK standard sets out other specific requirements foremergency and contingency facilities to be incorporated into habitats, including:

It shall be possible to rescue personnel from a submerged habitat even if the normal access cannot beused.

The habitat shall provide a dry and safe working area for the divers, shall be equipped with anadequate number of breathing masks, and should include a non-contaminated compartment.

Habitats shall be designed to make complete flooding impossible, leaving sufficient gas volume toallow personnel to dress into survival equipment and to allow personnel occupancy in an emergencysituation.

It shall be possible to close all pipe penetrations both internally and externally.

Guidance:

Any habitats which may be used in the Norwegian sector should comply with the requirementsof Section 7.2.8 of the NORSOK U100 standard.

8.3 Plant & Equipment8.3.1 Equipment for Emergency Thermal Balance

Although both sectors have requirements for the provision of plant and equipment foremergency situations, the UK sector is non-specific about the duration of support that is tobe provided. The ACoP para 121 states sufficient plant is available, whenever needed, which is

suitable to carry out safely any action which may need to be taken in a reasonably foreseeableemergency. The NORSOK U100 Standard is more specific when relating to equipment toprovide thermal balance in an emergency, Section 5.2.2.2 stating The minimum capacity foremergency situations shall be:

Divers in the water 10 minutes

Diving bells 24 hours

Chambers and HRVs 72 hours

Habitats 48 hours

Guidance:

An evaluation to verify the capability of the plant and equipment which is in place atthe dive site to maintain the thermal balance of the divers within acceptable limits forthe durations set out above, when working in the Norwegian sector, should beundertaken and documented.

8.3.2 Bail-Out DurationsIn both sectors requirements are in place for durations of bail-out systems.

In the UK Sector it has, for many years, been the practice for calculating the bail-out duration of1minute per 10m of divers umbilical at the working depth. This is to be calculated at aconsumption rate of35 l/min (based on AODC 014, published in 1983).

In the Norwegian sector the requirement is for bail-out duration of 10 minutes(irrespective of umbilical length) calculated on a breathing rate of62.5 l/min at the workingdepth.

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Guidance:

The bail-out systems should be capable of operating for the appropriate period for thesector.

8.3.3 System to Locate, Assist and Recover Bell/Habitat/ADSIn the UK Sector the diving project plan and associated risk assessment needs to identify and

ensure that the necessary systems and equipment are be put in place to locate, assist andrecover a bell/habitat or ADS.

In the Norwegian Sector the requirements are more specific:

NORSOK U100 section 9.1.2 states When undertaking manned underwater operations, meansto effectively locate, assist and recover the bell/habitat/ADS shall always be available. Such meansshall be an additional diving bell for depths exceeding 200msw, or, for shallower depths, a large ROVcapable of assisting units in distress, or additional ADS.

It further states that An ROV may, for instance, provide connections for necessary supplies toemergency panels on diving bells and submerged habitats, or attach emergency lifting gear on tounits that are unable to make use of ordinary facilities for recovery to the surface.

Guidance:

For diving operations deeper than 200msw in Norway, a twin bell dive system isrequired.

For diving shallower than 200msw in Norway, a twin bell diving system should be usedor a large (work class) ROV should be available to assist in location, assistance andrecovery operations.

8.3.4 Access to Telecommunications LinkIn both sectors there is a requirement to provide communications facilities betweenpersonnel who may be treating an injured diver and shore based specialists. In the UK sector

it is stated that this may be by radio or telephone, with pre-arranged methods of transferringinformation from the doctor to the site. In Norway, however, the requirement is morespecific. In NORSOK U100 section 5.1.6.3 it is stated The person performing advanced first aidshall have priority and unimpeded access to suitable telecommunications with the responsibledoctor. This is generally interpreted as a telephone link via the unscrambler system to thetreatment chamber.

Guidance:

A telecommunications link should be provided to allow the person in the chamber whois providing advanced first aid to speak directly with the shore based specialist.